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HomeMy Public PortalAboutPRR 14-12891269 RECEIVED 08/00/2014 13:51 5613946102 5EV 0810812014 14:12 Commerce Group P.0021003 RECORDS REQUEST (the "Request') Date ot'Request: 8/8/2014 Requestor's Request ID #: 133 REQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkas, P.L. REQUESTOR: Asset Enhancement, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: records @commerce- gmup.com Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Please provide all Public Records confirming the language Inserted in the fast sentence of paragraph 18 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan '[sic] And William Ring, Esquire, which was filed by ttorney Sweetapple. ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT, CHAPTER 119 OF THE FLORIDA STATUTES AND IS ALSO REQUESTED UNDER THE COMMON LAW RIGHT TO KNOW, THE COMMON LAW RIGHT OF ACCESS; AND ANY STATUTORY RIGHT TO KNOW (INCLUDING, WITHOUT LIMITATION, ANY STATUTORY RIGHT OF ACCESS, AS APPLICABLE). THIS REQUEST IS ALSO MADE PURSUANT TO THE RIGHTS OF THE REQUESTOR PROVIDED IN THE FLORIDA CONSTITUTION. IT 19 REOUESTED THAT THIS RECORDS REOUEST BE FULFILLED IN ELECTRONIC FORM. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REO IFaTED THAT THIS RECORDS REQUEST BE FULFILL 7 PAPER. NOTE: IN ES NLESS IM OSSIBLE THE COPIES H LD BE TWO SIDED AND H ULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) A. LLLELECTRONIC COPIES ARE REOLiF' -cTED TO BE Cr+'NT BY E MA,ii DELIVERY. PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will be required that the Requester approve of any casts, asserted by the Agency (as defined in Florida Statute, Chapter 119.01 (Definitions)), In advance of any costs imposed to the Requester by the Agency. I:MPJFRR 04.22.13 FORM RECEIVED 08/08/2014 13:51 5613946102 SBV 08108=14 14:12 Commerce Group MOS5436=7 P.0031003 Martin E. O'Boyle v. Town of oult5tresm CASE NO. 502Ql4CA004474xxxX v1BAG (PALM BEAM COUNTY) undertaken to pressure and intimidate defense counsel into not pursuing the issue of whether the O'Boyle Law Firm is a bona fide Interstate Law Fhm . I5. The issue of whether the O'Boyle Law Firm Is a bona fide Interstate Law Finn is one that should be resolved according to law. It should not be the subject of hauwameot, intimidation and air raids by opposing counsel and their client 16. The misconduct is unprofbasional, unethical and it constitutes an egregious example of litigation abuse. These tactics go beyond zealous representation and are designed to interfere with defense counsels' ethical obligation to their client. Such conduct undermines society's commitment to the resolution of disputes in courts of law, rather than in the streets or in the sky. 17. While citizens e'joy the constitutional right of free speech, that protection is afforded to truthful speech, and while attorneys must zealously represent their client's interests, they are also Officers of the court, and are prohibited fmm disparaging witnesses and Attomeys, or otherwise undermining the administration of justice. I8. It Is well settled that the trial court has inherent jurisdiction to sanction parties and their counsel for litigation abuse. In this instance, plaintiff and his counsel have sought to cease any litigation or determination of the bona fides of the O'Boyle Law Firm by threatening and instituting reprisals against counsel, their client and families, 19, While O'Boyle has the right to continue to make a spectacle of himself, he, with the assistance Of counsel, cannot impugn, malign and attempt to extort opposing parties or their counsel as part of the litigation process. 20. Abusive conduct is not a novelty for O'Boyle, who has left a historic trail of abusive litigation. 5 LAW OMM OFSwIIrAPEA BROMM& VAarne, F.L. 20 SZ3 31Ma61, BOCARATOKRI MA33432.3911 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail November 4, 2014 Asset Enhancement, Inc. [mail to: records @commerce- group.com] Re: GS #1289 (133), #1295 (123) Please provide all Public Records confirming the language inserted in the last sentence of paragraph 18 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C., Jonathan O'[sicj And William Ring, Esquire, which was filed by Attorney Sweetapple. Please provide all Public Records which confirm Attorney Sweetapple's statement in the first sentence of m(mbered paragraph 14 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C., Jonathan O'[sic] And William Ring, Esquire, which was filed by Attorney Sweetapple. Dear Asset Enhancement, Inc. [mail to: recordsaa commerce- eroun.coml, This letter is in response to the public records you have requested which we received August 8, 2014. Your original requests can be found at the following link http://www2.gulf- stream.org/WebLink8/0/doc/20082/Pagel.asi)x and httv://www2.eulf- stream.ore/WebLink8 /0 /doc /20088/Paeel .asox. Be advised that no such records exist. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records